Day 306 - 26 Nov 96 - Page 02
1 Tuesday, 26th November, 1996.
2
3 MS. STEEL: Sorry for the delay.
4
5 MR. JUSTICE BELL: Yes.
6
7 MR. MORRIS: Jack Russell, on the meeting of 26th April 1990,
8 it is going to take a little bit of time to go through
9 this. Basically, the long and short of it is that he could
10 not say anything connecting me to the fact sheet,
11 distribution of the fact sheet, and the things that he had
12 attributed to me he ended up saying that he did not know if
13 it was me saying that or somebody else saying that offer,
14 or an impression he got.
15
16 I wanted to go through a few references in his
17 transcripts. Day 263. I mean, there is a lot of stuff
18 about how -- well, his memory was clearly a hundred percent
19 reliant on his notes. In fact, I think it was a report
20 based upon his notes. I am trying to sort of shorten this
21 but I do not think I can. I will have to go through the
22 references I have identified.
23
24 At the top of page 50, day 263, he thought he may have gone
25 to another meeting but no one turned up. So he only went
26 to one meeting, but in fact none of the agents had
27 remembered him from a meeting. So his memory was clearly
28 not very good of that whole time. At the top of page 51 he
29 explains how I had been described to him before he went to
30 the meeting, so he was obviously looking out for me. He
31 could not remember if Paul Gravett was at the meeting or
32 not (bottom of page 52). He said I arrived at nine o'clock
33 (that is page 53, line 18) at this meeting. So, obviously,
34 I would not have anything to do, if that be true, in
35 bringing any material from the office or anything to that
36 meeting. Then he states something to the effect of -- hang
37 on, this is actually "Examined by Mr. Rampton", yes.
38 Mr. Rampton puts to him part of the report based on his
39 notes, I think it is the report based on his notes, about
40 me saying a whole great long spiel about going to Moscow
41 and then the international mail-out and he says to him:
42 "Are you quite certain in your own mind that it was
43 Mr. Morris who said all those things? Answer: Yes, I
44 am."
45
46 This is a feature of this case, on this part of the issue,
47 that the Plaintiffs are absolutely -- well, the Plaintiffs
48 are doing everything they can to get the witnesses to be
49 certain about things that they are clearly not certain
50 about; for example, identifying the London Greenpeace fact
51 sheet and we say it is a feature of -- well, it is pretty
52 clear that none of their publication witnesses could really
53 distinguish between the different kinds of "What's wrong
54 with McDonald's" leaflets, but that uniformly the
55 Plaintiffs have tried to straitjacket their evidence into
56 being certain about it, based upon inadequate notes and
57 non-existent memory from six years ago. Therefore, we say,
58 any of their apparent evidence on -----
59
60 MR. JUSTICE BELL: Have you and Ms. Steel worked out how you
